[Scandiravian]

Having experienced layoffs in both US and EU companies, the difference is massive. In my experience there is very little respect for "the human" being laid off in US companies

People literally would just disappear day to day. I've had several instances where I only found out a colleague had been fired because I tried to write them on Slack only to find that their account had been deactivated

Personally I felt constantly worried working in such an environment and I don't want to work for another US company again if I can help it

There are of course bad cases in the EU, but in my experience it's way less common than in the US

[bigfatkitten]

Layoffs in US companies are a BCP event. It's like an earthquake or a tsunami. Weeks of chaos while you figure out who survived, and who's now doing the work previously done by a team that no longer exists.

I watched a layoff take out half the security team during an incident. That was fun.

[Y_Y]

> A business continuity plan (BCP) is a system of prevention and recovery from potential threats to a company.

I feel like global acronym bankruptcy is overdue.

[Squeeze2664]

GAB, you mean?

[shagie]

I'm reminded of the last part of 'TLA' form the Jargon File (I had a hard copy back in college that I read cover to cover).

http://www.catb.org/jargon/html/T/TLA.html

...

The self-effacing phrase “TDM TLA” (Too Damn Many...) is often used to bemoan the plethora of TLAs in use. In 1989, a random of the journalistic persuasion asked hacker Paul Boutin “What do you think will be the biggest problem in computing in the 90s?” Paul's straight-faced response: “There are only 17,000 three-letter acronyms.” (To be exact, there are 26^3 = 17,576.) There is probably some karmic justice in the fact that Paul Boutin subsequently became a journalist.

[trelane]

Now I want to use the dictionary file to figure the actual probability of a letter appearing in a TLA. It's not nearly 1/26.

[shagie]

There's likely a good bit of analysis that could be done on TLAs. Consider TLA itself is {Adjective : Count} {Noun} {Noun}. Meanwhile, DUI is {Gerund} {Preposition} {Noun} with the stop word 'the' removed.

It might be interesting to take a sample of TLAs used and look what words can be used in those spots. If the third position is 90% likely to be a noun, that could change the distribution... guessing not in a significant way itself but it could be interesting to see.

[OrsonSmelles]

This is the best work I know on the topic (admittedly having done no literature review): https://gwern.net/tla

[siavosh]

BCP events. This makes so much sense. At a previous mega corp I was always confused why such emphasis was made on BCPs for war or natural disaster scenarios which are so rare compared to how much time was spent on the plans. Literally months later we had massive layoffs. The layoff was the (un)natural disaster they were preparing for!

[wyclif]

If anyone here has only worked in the EU and wants to see what the US layoff process is supposed to be on a good day, just watch the movie Margin Call and the scene where Eric Dale is called into the office by HR to be fired.

There's a scene where they put a folder in front of him with a brightly-coloured sailboat on the cover labelled "LOOKING AHEAD." It's exactly as grim as it sounds.

[jordanb]

Another "fun" thing about that movie is you see the HR lady who delivered the news with a bunch of false empathy walking out the building with a box in a later scene.

[bionsystem]

Watched this movie 3 times and never noticed! This is a fun touch.

[supportengineer]

That’s very subtle. I have not noticed that.

[BXlnt2EachOther]

also, the pacing of:

"I hope, considering your [pause to check personnel file] over nineteen years of service to the firm you will understand that these measures are in no way a reflection of the firm's feelings towards your performance or your character"

[acjohnson55]

Up in the Air was another great depiction of the most cynical mode of doing layoffs. And, of course, Office Space.

[fatnoah]

I was laid off by a consultant. It was somehow even worse than Up in the Air since they made my manager sit in on the call.

[supportengineer]

I know they probably made this up for the movie, but I almost went through my file cabinet to look for that exact folder because I have been through several layoffs and it looked so familiar

[spacemadness]

American companies play mental games and gaslight everyone by calling it “a hard decision” and try to place the empathy back on the executives who get paid 10-100x the employees they just fired without warning. It’s sociopathic behavior.

[eadmund]

I don’t think that’s really fair. It can certainly be a hard but necessary decision. And what does it matter that a CEO makes more than his employees? Even if he makes 50 times what they make, that means even if he gave up all of his salary he could only save the jobs of 50 employees.

[Viliam1234]

Could he get a bonus if he fires 50 more?

[yodsanklai]

> I don't want to work for another US company again if I can help it

You can work for a US company in the UE. They have to follow the local rules like anybody else.

[mycatisblack]

Having worked in a (now defunct) US co in West-EU I can say it’s a subtle blend of the two. The layoff was announced, shortly after a few people received a call by HR, were escorted to their desk by security and had to turn in all company belongings on the spot. They were not allowed to touch a computer or telephone and were then escorted out of the premises. Afterwards, we learned that they had received a severance package that met local rules.

Most of my colleagues were shocked by the treatment. Moral took a dive after that.

[yodsanklai]

I work for a US company but in western Europe. The layoffs have been much more humane here than in the US. There was a negociation process which lasted several months, and the severance was better and on a voluntary basis. I don't think a company making profit can easily get rid of employees over here, but probably depends on the country. Regarding performance-based layoffs, they did manage to fire people too, but again it was technically a common agreement.

That being said, if they want to get rid of employees, they always find a way. And the European market isn't as dynamic as the US one, so there are pros and cons. Personally, all things considered (risks of layoffs, PTO, cost of living) I'm happier in Europe but it really depends on individual situation.

[seanmcdirmid]

I wonder about the dynamic tradeoffs. Maybe a better example are labor markets that are even more dynamic than the USA (like China, despite having formal labor contracts). Maybe if jobs are so easy to get losing one won’t feel as painful.

[steveBK123]

Well US companies now take the cowards way out generally - tell everyone to WFH that day (despite prior RTO mandates) and then just disable peoples access so the first way the laid off find out is when they can't login for the day.

[wiether]

There are rules, but one can decide to not follow them.

One thing that I saw (but never experienced myself) happen with North American companies wanted to leave EU is just doing their usual things (thus not following local rules), and then people have to sue and wait many years to be compensated.

[InitialBP]

A company that has to "follow the rules" is way less desirable to work for then a company that embraces the spirit of the rules. I'm in the US so can't really speak for companies in other countries, but many US companies are doing everything they can to skirt the letter of the law and spending a ton of money to have them rewritten to be less favorable to employees and more favorable to the business. Finding a company that truly cares for employees is a very rare treat!

[int_19h]

It's a fundamental problem with large organizations.

In principle, an organization that is built on reciprocal loyalty is more productive than one that treats people as interchangeable cogs, because people are individually happier and go to greater lengths to achieve the shared goals, making them more productive. However, this arrangement can only be built on trust, and trust doesn't scale well past the Dunbar number. Thus, spirit of the rules is replaced by letter of the rules (which can be meaningfully enforced).

Thus, the larger the bureaucracy, the more soulless it is even in individual interactions between people within it, and the more it treats those people as interchangeable cogs that are there solely to serve the overall function of the organization. If the organization is a for-profit corporation, its overall function is profit, and thus megacorps always tend to optimize squeezing their employees.

Short-term this can be reversed somewhat if leadership is concentrated and opinionated. E.g. when the company grows out of a startup dominated by a single founder, and that founder has certain ethical standards or beliefs that they enforce on the org, overriding the natural tendency. This arrangement never lasts long-term, though - either the founder goes away and is replaced by generic management which has neither the desire nor the capacity to go against the current, or the founder becomes corrupt.

[Muromec]

That's absolutely happening in US-owned companies in EU that used to be great places to work before they became US-owned. They do pay a premium for their bullshit of course.

[gnfargbl]

Well, sure, but unless the US company is willing to set up an EU subsidiary and employ you via that then you'll be working as an independent contractor. That status gives you zero employment rights, because you're explicitly not an employee.

[jkaplowitz]

Many cases where someone is in practice functioning as a full-time employee are legally employment relationships according to both US and EU law even if the contract and payroll procedures say otherwise, and even if the contractual relationship is directly between a US entity and a worker in the EU. This includes whatever employment rights are supposed to exist, for the number of employees (whether or not misclassified as independent contractors) the company has in that country under its national employment laws.

Lots of US tech companies like to pretend otherwise, but a complaint or two from the misclassified employee can create plenty of pain for the employer for lying to both the US and foreign governments about the genuine nature of the relationship. And these penalties generally go not to the employee but to the employer, since the noncompliance is generally around employer tax, payroll, and reporting obligations as well as laws which are meant to protect employee rights.

[friendzis]

In practice, US tech companies literally buy their way out. They pay such a premium for those independent contractors that there would be no such complaints in the first place.

[jkaplowitz]

No complaints based on the amount of pay, maybe.

But for example, someone who is fired or laid off in a way that wouldn’t comply with local employment protections if the employment relationship were correctly classified might assert their misclassification claim so that they can also get compensation for their wrongful termination.

If that happens, then the company not only has to scramble to catch up on the overdue social contributions for the complaining employee and pay any applicable penalties, but also likely have to undergo an audit of their other workers in that country plus the same consequences for them.

There’s a reason why any US tech company that’s big enough to be a juicy financial target tends to do this correctly, and why companies like Deel, Remote.com, and their less tech-branded competitors (such as Velocity Global) are gaining popularity among people who want to do this correctly at smaller scales than those for which it makes sense to set up foreign subsidiaries.

When smaller companies take this particular shortcut, are risking severe financial consequences for the company if the authorities discover it, and in many cases this also comes with personal liability for some of the executives who are neglecting their legal duties.

[jonp888]

That's usually illegal, unless you're a genuine independent contractor that completes work packages for multiple clients.

If it was legal to work in the office of your only "client" 40 hours a week on a permanent basis, then any EU company could ignore the entire employment legislation of their real country by setting up a shell subsidiary in the US.

[gnfargbl]

I'm only familiar with UK rules on the topic, and of course the UK is no longer in the EU, but here at least the standard for determining employment status is quite complicated. The ability to work for multiple clients is one of the factors, as it speaks to the control and mutuality-of-obligation tests set by IR35, but it would probably not (alone) be enough to determine employment status either way.

> If it was legal to work in the office of your only "client" 40 hours a week on a permanent basis, then any EU company could ignore the entire employment legislation of their real country by setting up a shell subsidiary in the US.

That wouldn't work because it would be an obvious sham designed mainly to avoid the EU company's responsibilities under employment law. Courts see through those shams very quickly.

Technical people -- including me -- like to try and reduce the law to a series of digital if/then/else tests, but reality is much more analogue. If you're one of a small number of highly-experienced remote contractors engaged by a US-based client with no local subsidiary, the authorities are likely to accept the arrangement, or at least not to spend significant amounts of time investigating it. If you're one of very many Uber-driver-like "contractors" working for a company that is obviously dodging its local employment law obligations, then they're much more likely to be interested.

[Vinnl]

This can still happen:

> where I only found out a colleague had been fired because I tried to write them on Slack only to find that their account had been deactivated

The colleague will just be one that's based in the US, but that doesn't make it much easier.

[rickdeckard]

From my experience that often just prolongs the process, but doesn't change the management culture.

An employee decided to be laid off is equally written off immediately, it's just delegated to the regional/local HR to "manage the rest".

If you're not escorted off-premise, you get to enjoy some additional days/weeks of colleagues and managers telling you how surprised they were...

[slac]

The EU is not a country. Labor laws vary massively between countries.

[apwell23]

> In my experience there is very little respect for "the human" being laid off in US companies

its much easier to find another job in US because of this though.

[oblio]

Is it, really? Aren't US tech interview notoriously difficult? Many rounds of interviews, background checks, etc.?

Most purely European companies don't do that. Actually, unfortunately, some of them do, because of American influence. But for sure they didn't use to.

[scarface_74]

There are 2.8 million developers in the US. Most of them don’t work for “tech” companies. Most of them work for boring enterprise companies without multiple rounds of enterprise companies and many let you just do behavioral questions and techno trivia on the stack they care about.

I personally have interviewed for 7 enterprise dev jobs and I have had 2 coding interviews and those were simple.

[Tainnor]

IME, this was true four years ago. Few rounds, assessments were mostly take homes or in-person "implement a feature" style, interview questions didn't seem to be built to trip you up.

Now, every job I apply for has 4-5 rounds, leetcode is more common, they do behavioural and system design rounds that you have to prepare for, etc. One job I applied to even asked me two behavioural questions via email before I even talked to someone. Something's truly off.

[Kaethar]

Wait till you get a self recorded behavioral interview. I truly wonder if there is that much value to be extracted out of 10 minutes of people awkwardly responding to questions while trying their best to fill in the silence.

[Tainnor]

I think I'm not yet desperate to the point that I would agree to that.

[selimthegrim]

I had to do one of those for some local government lobbyists association in DC. They ended up hiring some undergrad instead.

[constantcrying]

Of course. Companies who fire more also hire more.

European companies have very little staff turnover, so new jobs are fewer. Another aspect is that salaries are very even across much of the industry, as it is often negotiated by unions and unless you are also switching roles (e.g. into management) salaries at different companies will be very similar. That is why working for the same company for a long time is much more common in Europe.

[disgruntledphd2]

> Another aspect is that salaries are very even across much of the industry, as it is often negotiated by unions

Can you specify what country you're drawing these facts from? Europe does not have standard employment law, and I definitely haven't experienced salaries being set by unions or being common across the industry.

[constantcrying]

Germany in this case. The high tax rates at progressive rates mean that salary increases mean that income after taxes is quite flat.

There are also union negotiated rates for pay across much of the industry. Even if you switch employer your pay might remain exactly the same, unless you also get promoted and into a higher level or a different industry. "Flächentarifvertrag" it is called.

Obviously this drastically disincentivizes hoping employers.

[disgruntledphd2]

> Germany in this case. The high tax rates at progressive rates mean that salary increases mean that income after taxes is quite flat.

OK, good to know. I definitely haven't experienced flat income after taxes post salary bump, even though I pay 52% marginal on my income (in Ireland).

> Obviously this drastically disincentivizes hoping employers.

I can totally see that. Is it really that common in tech jobs though? I'd have expected this to be much more common in larger, older companies (like the automotive industry).

[bluedino]

> Aren't US tech interview notoriously difficult? Many rounds of interviews, background checks, etc.?

Not really, people get hired all the time that can't do a fizzbuzz.

[femiagbabiaka]

As a counterpoint, I don't think I've worked at a company in 10 years that didn't at least require fizzbuzz.

[icemelt8]

What he meant is that the whole capitalist culture, less regulations, creates a more thriving economy which creates more jobs and hence more options to go to.

[hnlmorg]

I've heard this type of comment a lot but in my experience there isn't any shortage of tech companies in the EU.

What EU regulations hamper isn't job creation, it's employee and customer exploitation. The distinction between "job creation" and "employee exploitation" is important.

What the former means in practice is that there is a massive contractor market in the UK and EU. So if companies need temporary staff, they'll hire a contractor. If they need permanent staff then they'll hire an employee. And contractors in the UK & EU are paid significantly more than their employee peers. In fact their pay is much more equivalent to US employees. So companies will make constant tradeoffs between more expensive labor for short-lived projects vs cheaper staff and knowledge retention but stricter employment laws. It's a fair trade most of the time.

So a more accurate way of comparing US vs EU businesses in terms of employees would be US employees vs EU contractors. Things then begin to look a lot more equivalent.

[scarface_74]

I doubt the tech workers making three to four times EU wages in the US feel “exploited”.

My job is purely transactional. I’ve worked for 10 companies in almost 30 years. I gave them labor and they gave me money. Whenever one side decided the arrangement wasn’t working, I moved on to another job.

[Spooky23]

Tech is always boom/bust. We’re lucky to have had a long boom.

I’m personally well acquainted with many people in tech, especially big tech. Many of them are doing little or nothing, certainly not justifying $300k+ salaries.

What you do has risk but is fundamentally more honest - your skills are around technology and output, not navigating corporate bureaucracy.

[hnlmorg]

You're focusing on one word and missing the meat of my comment. The EU equivalent to US employment in terms of employee rights and pay is contracting.

People in IT who take the employment route rather than contracting, do so because they want job security. eg they might have families. And much as you might be happy with your arrangement, there are plenty in the UK and Europe who do prefer longer-term job security over a few extra £££ in their pocket.

[apwell23]

this doesn't make sense. so why do usa companies hire contractors then? I worked as a contractor for decades and made 150% what perm employees made.

[hnlmorg]

That I don't know. But the contractor market in the US is very different to the contractor market in the UK and EU. And from hiring in both US and UK, my experiences have been that US employees are more comparable to UK contractors in terms of rights and pay.

[amalcon]

There are more regulations around employees than contractors here also, which often makes it not worthwhile for short term workers. Those regulations just mostly aren't around when you may terminate employment.

E.g. the entire I-9 thing and other IRS paperwork, who (if anyone) is responsible for various insurances (unemployment insurance, workers comp, liability insurance, etc), minimum wage and overtime for hourly employees, etc. Many things depend on this distinction.

I can't speak to differences from Europe as I am not familiar with that side of the Atlantic.

[homefree]

Yeah I’d argue this is so clearly the case and it’s one reason among many why the US has an enormous amount of successful tech companies and Europe has some amount that basically rounds to zero in comparison.

The ability to hire and fire easily is critical if you want to build successful companies.

There’s a reason ambitious founders move from Europe to the US and why most billion dollar tech companies are American. Europe has made really bad policy decisions around this for decades and their economy reflects it. Europe is poor and to an extent I don’t think Europeans really understand.

[disgruntledphd2]

> There’s a reason ambitious founders move from Europe to the US and why most billion dollar tech companies are American.

Yes, and it's because of larger, more liquid capital markets make it much easier to obtain VC funding.

> Europe is poor and to an extent I don’t think Europeans really understand.

Europe is definitely not poor in terms of either wealth or income (particularly Western Europe, which is the appropriate comparator for the US).

[tempfile]

Indeed, but that is just ideology, not based on any facts.

[apwell23]

low eu salaries implies finding job is hard. fact.

[Scandiravian]

There's a higher monthly salary in the US, sure. However, you're expected to work very long hours (60-80 hours per week) and get basically no time off

In my current position I'm hired for an expected 37 hours per week. This can be more if I'm asked to work overtime, but my weekly hours cannot exceed 45 hours per week on average in a 3 month window without additional compensation

Additionally I have six weeks of paid time off every year plus public holidays

If I calculate my hourly salary it's better than what I was paid by US companies

That's not to mention the security of having a legally mandated termination period of minimum 3 months (in which you're, in most cases, not expected to work)

[tempfile]

What a waste of a comment. Low salaries typically imply finding a job is easier, because more potential employers can afford to pay you. Can you add any kind of evidence, argument, anything? Saying "fact" after an armchair guess does not make it one.

[perching_aix]

> low eu salaries implies finding job is hard. fact.

Does it? Sounds more like an opinion than a fact to me.

[tjpnz]

In Japan firing an employee is difficult and layoffs are unheard of. I would have few concerns finding something new were that to change overnight here.